Shop Towels

ECAR Fact Sheet for Colorado
Shop Towels

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

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The following fact sheet was prepared by the ECAR Center staff. Once prepared, each ECAR Center fact sheet undergoes a review process with the applicable state environmental agency(ies). You can check on the status of the review process here. Please read the disclaimer on the status page. While we have tried to present a summary of the essential information on this topic, you should be aware that other items, such as local regulations, may apply to you.

What You Need to Know

When you absorb toxic or flammable material in a towel, you haven't made it any less toxic or flammable. Depending on what they have been used for, shop towels may need to be managed as hazardous wastes. But you may be able to be exempt from the full burden of hazardous waste management rules if you send your towels to a qualified industrial laundry service. (The service has to discharge its wastewater into an approved wastewater treatment facility -- it can't discharge directly to a river or stream, for example.) If you do not send your towels out for cleaning (for example, if you use disposable towels), then the burden is on you to prove that they are not hazardous before you dispose of them. Reusable towels and a qualified laundry service are by far the best bet.

The Colorado Department of Public Health and Environment (CDPHE) has prepared a guidance document to help auto recyclers manage shop towels. Much of that information is included in the fact sheet below. You can access the link to the CDPHE's Shop Towel Compliance Bulletin under Other Relevant Resources.

Regulations

Rags, shop towels, and other reusable absorbents that are contaminated with listed hazardous waste or that exhibit a hazardous waste characteristic are considered to be exempt from the provisions of the Colorado hazardous waste regulations only if they are picked up, cleaned, and delivered back to the customer by a laundering service which uses a solvent-based dry cleaning process to clean the rags, or a water-washing commercial laundry with all appropriate waste water discharge permits from the local municipal waste water treatment plant.

The preferred alternative is commercial dry cleaning, because this process enables recovery and destruction of the contaminants removed during the dry cleaning process. Materials contaminated with solvents, resins, lacquers, etc., cleaned in commercial water-washing facilities are simply transferring the contaminants to the water, which is discharged to the sanitary sewer. The water is then treated by the municipal wastewater treatment facility.

Laundering Shop Towels On-Site. Laundering may be done at your facility under certain conditions. Reusable absorbent materials cleaned by such contractual/closed loop cleaning services would not have to be managed as hazardous waste when on site; do not need to be shipped under a manifest to a licensed hazardous waste treatment, storage, or disposal facility, and do not count toward the total monthly on site generation of hazardous waste. In order to launder shop towels on-site, you must meet the following conditions:

You receive written approval from your local sewer district.

Storage of Shop Towels: You are responsible for the safe storage of ignitable/flammable materials from the time of generation until the time that they are picked up by a commercial laundry facility.

The used absorbent materials must be stored in sealed, labeled waste containers.

No Free Liquids. The rags, shop towels, or absorbents would not be exempt from the hazardous waste regulations if free liquid hazardous waste is dumped onto the absorbents or if the absorbents are saturated with free liquid hazardous wastes. One way to ensure that no free liquids are present would be to wring out the soiled materials and collect the released liquid for proper hazardous waste handling and disposal.

Absorbents. Any absorbents that are contaminated with a listed hazardous waste or that exhibit a hazardous characteristic and are not commercially dry cleaned or laundered must be handled as hazardous waste. If you are unsure as to the type of waste involved, you should make a hazardous waste determination prior to disposal.

Links to the Regulations. Use the following links to view the regulations pertaining to shop towel management and storage.

Colorado Hazardous Waste Management Requirements

Federal EPA Standards Applicable to Generators of Hazardous Waste

Self-Audit Checklist

When an inspector comes to your facility, there are certain things he or she checks to see if you are in compliance with environmental regulations. It makes good sense for you to perform a "self-audit" and catch and correct problems before they result in penalties. Also, there are some compliance incentives associated with self-audits (see Audit Policy Page).

Use the following list to audit your handling of used shop towels.

Shop towels are exempt from regulation only if they are managed in certain ways. Verify that dirty shop towels are managed correctly and picked up for laundering by an industrial laundry service that is connected to a publicly owned treatment works facility (POTW), or which uses a solvent-based dry cleaning process to clean the rags. You must manage your shop towels in accordance with the hazardous waste requirements until they leave your operations.
Do your shop towels contain free liquids? If so, there is no hazardous waste exemption for rags or soiled clothing contaminated beyond saturation.

Best Management Practices (BMPs)

Most regulations tell you what you have to do to be in compliance, but they don’t explain how to do it. That’s where "best management practices" come into play. BMPs are proven methods that help you to get into compliance and stay there. The following BMPs are recommended for handling used shop towels.

Avoid using disposable towels. Use cloth towels from an industrial laundry service that is discharging its wastewater into a public sewer system.
Do not dispose of solvents by pouring them onto rags or into containers of used shop towels.
Do not saturate your towels. If you do, wring them out and reuse the liquid.
Do not throw dirty wipes, paper towels or rags into the dumpster if they have come into contact with hazardous solvents or waste.
Do not dispose of dirty shop towels in vehicles to be crushed or shredded.
Keep waste shop towels in a closed, fireproof metal container labeled "Used Shop Towels."
To reduce the risk of spontaneous combustion when storing shop towels in metal cans, keep the towels moist with water.
Examine your equipment cleaning practices to identify opportunities to reduce their frequency, thereby reducing the number of towels, wipes, or rags that are used for this purpose.
Maintain records of analytical waste determinations and disposal receipts for at least 3 years.

Contacts

For more information, contact the Colorado Department of Health and Environment's technical assistance line at 303-692-3320, or toll-free at 888-569-1831, if outside of the 303 area code.
To report a spill or leak, at minimum, call the Colorado 24-hour Emergency Spill/Release Reporting Line at 877-518-5608 and the Local Emergency Planning Committee at 303-273-1622, immediately or within 24-hours. Refer to the Spill Response Fact Sheet to determine your reporting requirements.
To report an environmental incident or complaint, contact the nearest regional office.

Related ECAR Fact Sheets

Other Relevant Resources